Response to Comments, SPI-Loyalton Draft PSD permit #SAC-87-01A

August 30, 2010

EPA received six comments on the Sierra Pacific Industries –Loyalton (SPI-Loyalton) Draft PSD permit 

#SAC-87-01A. The commenters’ main concerns were related to particulate matter (PM) / soot and the proposed 

emissions increases in oxides of nitrogen (NOx) and carbon monoxide (CO). 

Particulate matter and soot deposits may be attributable to particulate sources affecting Loyalton 

neighborhoods. The District has informed EPA that there are local efforts underway to help understand the 

Loyalton–area PM problem, including the identification of potential sources, and possible PM reduction 

opportunities. On April 15, 2010, the District, SPI and the community, met to discuss the Loyalton Particulate 

Matter Reduction Plan.

To control PM emissions at the plant, SPI employs multiclone and electrostatic precipitator control devices 

for the control of particulates less than or equal to 10 micrometers in diameter. These PM controls are typical 

pollution controls applied to reduce particulate matter from biomass boilers such as the Riley stoker boiler in 

operation at SPI-Loyalton. 

EPA’s draft PSD permit for SPI-Loyalton included PM and VOC emission limits in Permit Condition

XII.D and relevant sections of the Ambient Air Quality Impact Report. After EPA announced the public comment 

period, EPA learned that the SPI-Loyalton permit issued by Northern Sierra AQMD (NSAQMD) already includes 

enforceable conditions limiting PM and VOC emissions. 

NSAQMD Permit #88-19-01, includes particulate matter and VOC emission limits in Permit Condition 26. 

PM is limited to 9.96 pounds per hour (averaged over 3 hours); 43.6 tons per year; 0.015 grains per dry standard 

cubic foot of exhaust gas corrected to 12% CO2. VOCs are limited to 10.5 pounds per hour (averaged over 3 hours); 

29.4 tons per year. In addition, NSAQMD recently clarified SPI-Loyalton’s compliance obligations by revising 

permit terms containing source testing requirements. Permit Condition 33 now prescribes the following: 

performance tests for emission of PM-10 shall be conducted using 40 CFR Part 60, Appendix A, Methods 1-4 and 

Method 5. For VOC emissions, the permit requires testing using EPA Methods 1-4, 18 and 25A to assure 

compliance. 

Because the permit issued by NSAQMD contains enforceable limits on PM and VOC emissions, and these 

emissions will not exceed PSD significance levels, EPA is not including PM and VOC limits in the final PSD 

permit. 

EPA’s final SPI-Loyalton PSD permit addresses increases to NOx and CO levels. To control NOx and CO 

emissions, SPI employs a noncatalytic reduction system with ammonia injection, and good combustion practices, to 

control NOx and CO, respectively. The analysis of proposed NOx and CO emissions increases indicate that 

expected concentrations fall within acceptable levels. Please refer to the Ambient Air Quality Impact Report in EDocket, http://www.regulations.gov/search/Regs/home.html#docketDetail?R=EPA-R09-OAR-2010-0226.

If commenters would like to discuss their issues further, you can contact Manny Aquitania at (415) 972-

3977, or aquitania.manny@epa.gov. At this time, EPA does not find sufficient justification to conduct a public 

hearing.